^ > 

Ronald J. Hinderberger The Boeing Company 

Lead Administrator P O. Box 3707 MC 03-52 

Delegated Compliance Org Seattle. WA 98124-2207 

Commercial Airplanes 

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BDCO-11-00741 

U.S. Department of Transportation J " j ; - i." '—\ 

-••{-• . Docket Operations (^: ;—«O o 

West Building Ground Floor, Room W12-140 ^ 

1200 New Jersey Avenue, S.E. co 

Washington, D.C. 20590 

Subject: Petition for Amendment to Exemption 9793 B 

Model: 747-8F 

BDCO Project No.: PS05-0212 

EASA Project No.: P.EASA.IM.A.164 

EASA Level: N/A 

Branch/Panel No.: ANM-150S 

Branch/Panel Name: Cabin Safety 

Response Due: March 31, 2011 

Reference(s): (a) Regulatory Docket No. FAA-2008-0348, 

Partial Grant of Exemption 9793B, dated 

October 22, 2010 

Special Instructions: N/A 

This letter is to submit: 

(X) Petition for Amendment to Exemption 9793B 

A revision to reference (a) Partial Grant of Exemption is required to allow the 

installation of the crew slide without extensive, costly and Program delaying 

changes. With this petition, Boeing is requesting the FAA amend Limitation 12 

and provide relief from the illumination requirements for the airplane in the tail 

down attitude with the escape slide installed. Additionally, Boeing is requesting 

removal of Limitation 17c anticipating that 14 CFR 25.809(a) Amendment 116 

will be removed from the 747-8F certification basis by exception. 

To support 747-8F/-8 program schedules, The Boeing Company requests that the 

enclosed information be processed by March 31, 2011. Furthermore, The Boeing 

Company requests to be notified when the enclosed petition processing has 

completed. 

Waiver from Public Comment 

This petition to Amend Exemption 9793 B will not set a precedent and 

accordingly. The Boeing Company respectftilly requests a waiver from the 

publication and public comment period of this Exemption. The Boeing Company 
( ^ 

Page 2 

Mr. Breneman 

BDCO-11-00741 

believes that good cause exists to waive the publication and comment 

requirements of 14 CFR 11.85, 11.87 and 11.89. 

This letter is being sent for: 

(X) Posting to the Federal Docket 

Please contact this office or the following individuals if you have further 

questions: 

Project Administrator (PA): 

Certification Specialist; 

J Potocki 

G. Gillette 

425-266-7473 

425-266-7484 

The information being forwarded to the FAA by or with this correspondence is 

for the exclusive purpose of support of applications for or amendments to Type 

Certificates, is considered proprietary to The Boeing Company and/or its 

suppliers, and is provided on a confidential basis. 

The data provided should be returned to Boeing immediately following use by 

the FAA, including any copies thereof which the FAA may be required to make 

in the course of its review. Boeing does not authorize the FAA to retain any 

portion of the materials being supplied. 

Very truly yours. 

Christine Thompson 

Lead Project Administrator, Development Projects 

(425) 266-6572, MC 03-56 

FAX: (425)294-9340 

Enclosure: Petition to Amend Exemption 9793B 

cc 

Name Letter 

Gary Oltman EDT 

Dinesh Indurkar EDT 

Julie Zachary EDT 

Rene Buendia EDT 

Jayson Claar EDT 

Enclosures 

EDT 

EDT 

EDT 

EDT 

EDT 

Comments 

ANM-IOOS 

ANM-102S 

ANM-102S 

ANM-150S 

ANM-115 
Enclosure to BDCO-11-00741 

Petition to Amend Exemption 9793B 

Name and Address of the Petitioner 

C M . Thompson, Manager, Lead Project Administrator, Development Projects 

The Boeing Company, 

PC Box 3707, 

Seattle, Washington, 98124 

B. Section of the Code of Federal Regulations (CFRs) that are Affected 

As provided for in 14 CFR 11.61(b), Boeing hereby petitions for revision to 

Exemption 9793B as follows: 

Reauirement 

Exemption 

9793B 

Exemption 

9793B 

Limitation 

12 

17c 

Which Reauires 

For the crew service door, emergency lighting must provide 

adequate illumination at the ground end of the assist means, where 

an evacuee would normally make first contact with the ground, with 

the airplane in each of the attitudes corresponding to the collapse of 

one or more legs of the landing gear and worse case center of 

gravity location. This condition does not apply to the overhead hatch. 

For the crew service door, the viewing outside through the viewing 

window does not meet the requirements of § 25.809(a). With the 

door closed it is acceptable to only be able to view the general 

location where occupants would likely make first contact using the 

optional escape slide in normal gear conditions and lower sill height 

conditions. After the crew service door is open all locations where 

occupants would likely make first contact using the optional escape 

slide and/or the inertia reels must be visible from the exit opening. 

The Extent of Relief Being Sought 

While the 747-8F airplane has considerable capability for exterior emergency 

illumination - see section D - the following relief is necessary: 

Regulation Reauires: Relief is necessary because: 

Exemption 

9793B 

Limitation 12 

Adequate illumination (post 

evacuation means deployment) at the 

ground end of the assist means used 

at the crew door for all gear collapse 

conditions. 

The illumination provided at the crew door is 

partially obstructed by the escape slide in 

the tail tip condition only (when inertia reels 

are used over the escape slide). 

Exemption 

97938 

Limitation 

17c 

Viewing of the ground contact area: 

1) With the door closed to view the 

general location of the escape 

slide in normal and lower sill 

conditions. 

2) With the door open to view all the 

first contact locations for both the 

escape slide and inertia reels 

The certification basis of the 747-8F is 

anticipated to be updated to remove 14 CFR 

25.809(a) at Amendment 116 from the 

requirements and thus relief from 14 CFR 

25.809(a) Amendment 116 is no longer 

necessary and the limitation imposed by 

9793B can be removed 

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Enclosure to BDCO-11 -00741 

D. Description of the Issue 

The Model 747-8F is a derivative aircraft based on the 747-400F. The fuselage of 

the 747-8F is 220" longer than the 747-400F. The 747-8F emergency exits, exterior 

body-mounted light for the escape slide and the escape means are the same design 

as the 747-400F with the exception that the escape slide is a customer selectable 

option on the 747-8F where as it was basic on the 747-400F. For the 747-8F, the 

escape slide has been selected by all current customers as the evacuation means 

at the crew door. A new body-mounted exterior light was added to the 747-8F to 

illuminate the ground contact area of the inertia reels when used independently, but 

it will also provide some illumination for the ground contact area of the escape slide 

in the tail down attitude when the inertia reels are used over the escape slide. The 

illumination provided by the inertia reel light of the ground contact area for the inertia 

reels used over the escape slide in the tail down attitude and the impact of 

Exemption 9793A/9793B Limitation 12 is the subject of the petition herein. 

Like the 747-400F, the 747-8F has a required flight crew of two (2) and is allowed 

the carriage of up to six (6) supernumeraries. Like the 747-400F and its 

predecessors, the 747-8F AFM will limit the airplane to eight (8) occupants. The 

eight (8) inertia reel descent devices located on the flight deck are identical in part 

number and location to the 747-400F and will be included on all 747-8F airplanes, 

with one for each airplane occupant to use either through the crew door or from the 

flight deck overhead exit. Additionally, there are eight (8) harnesses installed basic 

in the 747-8F supernumerary seating areas, two (2) more than the 747-400F, one 

for each occupant to don and connect to their descent device before evacuating the 

airplane. 

In summary the 747-8F airplane has the following capability for exterior emergency 

illumination to meet the 9793B Limitation 12 and only minimal relief is required as 

noted above. 

Regulation Reauires: Capability of the 747-8F 

Exemption 

9793B 

Limitation 12 

Adequate Illumination 

(post evacuation means 

deployment) at the ground 

end of the assist means 

used at the crew door for 

all gear collapse 

conditions. 

0.03 FC of illumination Is provided at the ground end of 

both the inertia reels and escape slide, at the crew 

door, in all conditions of gear collapse except in the tail 

down attitude when the inertia reels are used over the 

escape slide where the inertia reel light provides some 

illumination. 

The airplane capability will be described in further detail below. 

Illumination of evacuation means (post deployment) 

A method to show compliance to 14 CFR 25.812 for escape slides involves 

calculating the illumination levels of a rectangular grid of points placed at the toe 

end of the slide. Illumination levels of each point are calculated based on the 

performance measures of the light and the distance of the point from the light. 

Page 2 of7 
Enclosure to BDCO-11-00741 

A new body-mounted exterior light was added to the 747-8F to illuminate the ground 

contact area of the inertia reels when used Independently. This new inerlial reel 

light was designed to 14 CFR 25.812 Amendment 120 thus providing adequate 

illumination in all combinations of gear collapse and meeting Exemption 9793B 

Limitation 12. The inertia reel contact points for all gear conditions was used in 

development and placement of the new body-mounted exterior light. 

The existing exterior body-mounted light, designed to provide illumination for the 

escape slide, adequately illuminates the ground contact area of the escape slide in 

all combinations of gear collapse except the tail down attitude. In the tail down 

attitude, the exterior body-mounted light does not shine in the appropriate direction 

to provide the illumination as it was originally designed for the 747-100 to 14 CFR 

25.812 Amendment 28 (normal gear). 

It should be noted that the length of the escape slide will require that inertial reels be 

used over the slide if the airplane is in a tail down attitude and evacuation occurs 

through this exit. When the slide is deployed in this condition, initially, it will not 

touch the ground. If an evacuee enters the slide (with a reel) the weight of the 

evacuee will force the slide down until the toe end of the slide reaches the ground 

resulting in a slide too steep to use without inertia reels. In this condition, the inertia 

reel light provides some illumination of the ground contact area. 

Both exterior lights will be installed on all airplanes regardless of evacuation means 

selected by the customer. These lights are activated (1) automatically upon loss of 

main electrical power (28 VDC bus) when the system is armed, or (2) manually via 

the emergency light switches located on the flight deck or in the supernumerary 

seating area. 

E. Statement of No Adverse Affect on Safety 

The petitioner strives to provide acceptable safety conditions such that 747-8F cargo 

operators can safely operate their airplane with evacuation means and procedures 

consistent with the current fleet. The majority (5 of 6) of the airiine customers that 

have purchased the 747-8F also operate fleets of eariier model 747 Freighters, 

including the 747-400F. The surest, safest, and most cost effective manner of 

operating these cargo aircraft is to have consistent airplane designs and 

crew/supernumerary training with respect to evacuation safety features of the 

airplane. A grant of Exemption will result in consistent operator's procedures for 

evacuation of the 747-8F with the 747-400F fleet when the escape slide is installed 

and similar to other airplane models with only inertia reels installed, thus enhancing 

safety. 

It is proposed that the FAA provide relief from Limitation 12 of Exemption No. 

9793A/9793B for illumination of the tail down attitude when the escape slide is 

installed. Exemption No. 9793A/9793B Limitation 12 requires in part; "For the crew 

service door, emergency lighting must provide adequate illumination at the ground 

end of the assist means, where an evacuee would normally make first contact with 

Page 3 of7 
Enclosure to BDCO-11-00741 

the ground, with the airplane in each of the attitudes corresponding to the collapse 

of one or more legs of the landing gear and worse case center of gravity location." 

An acceptable level of safety is maintained without showing compliance to 

"adequate lighting" of the tail down aftitude when the escape slide is installed based 

on: 

o Limited number of trained supernumeraries 

o Probability of occurrence of evacuation in a tail down attitude in dark 

conditions 

o Illumination provided adjacent to the ground contact area is well above the 

minimum 0.03 foot candles established by 14 CFR 25.812 

o The illumination condition requirement is better than for evacuees using the 

flight deck overhead exit 

o Evacuees cannot drastically alter their landing location 

o Maintaining all of the other aspects of Limitation 12. 

The personnel (maximum of 8) aboard the 747-8F are required to be briefed by the 

flight crew prior to each flight on the use of the exits in accordance with Exemption 

No. 9793/9793A/9793B. This additional level of knowledge afforded to these 

occupants when compared to the normal passenger provides an enhancement in 

evacuation. 

The probability, based on the 747 fleet, of an evacuation in a tail tip condition 

combined with dark conditions is extremely improbable. This improbable event also 

justifies an acceptable level of safety provided for the airplane. 

The illumination provided by the inertia reel light at the ground area adjacent to the 

ground contact area where a person would land when using the inertia reels over 

the escape slide when the airplane is in the tail down aftitude is well above the 

minimum 0.03 foot-candles required for 14 CFR 25.812 compliance and thus some 

areas of the ground contact area are likely to be at or above minimum requirements 

due to reflected light. 

The illumination available from the inertia reel light for the ground contact area when 

evacuees are using inertia reels over slide during an airplane tail down event is 

better than for evacuees using inertia reels from the flight deck overhead exit during 

the same type of airplane event. 14 CFR Part 25.812(h) Amendment 128 has 

established for flight deck exits that it is acceptable to not provide illumination of the 

contact area. It is understood that the training afforded to the flight crew as well as 

the typical evacuation means and location of the exit are considerations for not 

requiring the illumination. Flight crew exits are typically an overhead exit or flight 

deck window utilizing ropes or inertia reels. As such the landing location cannot 

typically be seen until an individual is past the point of no return and thus providing 

illumination of the landing area was considered unnecessary. Additionally, the 

landing location once the evacuation has been commifted cannot drastically be 

altered as the individual progresses down the rope/inertia reel. Similarly, the 

supernumeraries on the 747-8F are required to be trained in the evacuation 

procedures. In this improbable case of a tail down aftitude with the escape slide 

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Enclosure to BDCO-11-00741 

installed, the supernumeraries may choose to exit out the crew door using the inertia 

reels over the escape slide. In this case, the controlled descent of the inertia reels 

will slow the evacuation, but the landing location cannot be drastically altered, so 

providing a level of illumination at the anticipated contact point is of limited benefit. 

The fact that some illumination will be surrounding the contact area is befter than 

what is required by the regulations for flight deck exits. 

Finally, as noted above in the description of the issue, all other evacuation gear 

collapse conditions (for both evacuation means) will have adequate illumination 

provided utilizing 0.03 foot candles as a minimum for compliance to Limitation 12. 

F. Proposed Revision to Limitation 12 

Request to Revise Limitation 12: The petitioner hereby requests the FAA revise 

Limitation 12 to remove the requirement for adequate illumination in the single 

condition of a tail down aftitude when inertia reels are used over the escape slide. 

Boeing proposes the wording as follows (additions from Exemption 9793B shown in 

bold and deletions shown with strikethrough). "For the crew service door, 

emergency lighting must provide adequate illumination at the ground end of the 

assist means, where an evacuee would normally make first contact with the ground, 

with the airplane in each of the attitudes corresponding to the collapse of one or 

more legs of the landing gear and worse case center of gravity location except for 

the tail down attitude where inertia reels are used over the escape slides, for 

which no illumination level is required.. This condition Illumination 

requirements does not apply to the overhead hatch." 

G> Proposed Removal of Limitation 17c 

Request to remove Limitation 17c: The petitioner hereby requests the FAA 

remove Limitation 17c in its entirety and remove all references to 14 CFR 25.809(a) 

at Amendment 116 as the certification basis of the 747-8F is planned to be updated 

via exception to 14 CFR 25.809(a) at Amendment 114. 

H. Statement of Public Interest 

The public interest will be advanced by the grant of Exemption as it is in the best 

economic interest of the United States. Increased sales of airplanes contribute to 

the balance-of-trade, the gross domestic product and economic health of the United 

States. Marketability of the 747-8F is improved, leading to increased sales, by 

keeping the sales price and operating cost of the 747-8F down while providing 

flexibility to the airiines in a choice of evacuation means. 

Purchase prices could increase due to design changes, additional exterior bodymounted lights, associated with providing a fully compliant design for illumination of 

the escape slide evacuation means. 

Operating costs are kept down by: 

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Enclosure to BDCO-11-00741 

o Having common training and operating procedures with the 747 Freighter 

Fleet when the escape slide is installed while avoiding the cost of maintaining 

different material in the training, maintenance, dispatch and operations 

manuals for the 747-8F and 747-400F. Every 747-400F delivered from 

Boeing was equipped with an escape slide installed in a similar interior 

configuration and an exterior body-mounted light to illuminate the evacuee 

ground contact area of the escape slide. The majority of the airiine 

customers that have purchased the 747-8F also operate fleets of earlier 

model 747 Freighters and will have the escape slides installed on their 747-

8F, same as the 747-400F. 

o Common training and operating procedures to other freighter models for 

those airiines selecting only the inertia reels as the evacuation means. 

o Avoiding the weight and fuel penalty and system maintenance costs including 

any economic penalties associated with flight delays that would otherwise be 

realized by the required design changes as noted above in the purchase 

price impacts. 

o Weight and fuel benefits for operators choosing the inertia reels as the 

evacuation means 

Lower purchase and operating cost will help maintain cargo shipping rates aboard 

Freighter airplanes at their current levels, which benefit the US economy as a whole. 

Grant of Exemption as requested in this petition is in the best interest of the 

travelling public through introduction of this new product into the marketplace that 

has advanced the certification basis in many areas as compared to the 747-400F. 

Enabling common operating procedures for evacuation not only maintains purchase 

price and operating cost as noted above, but avoids the potential for human error 

which may be introduced when procedures vary substantially for similar products. 

For the reasons noted above, it is the petitioner's opinion that the overall level of 

safety is improved by comparison to the previous 747 Freighter models that are 

certified with similar configurations and evacuation systems and safety is maintained 

which is in the public's best interest. 

Request for Waiver of Publication 

The petitioner requests that this petition for exemption not be delayed by the public 

process, which includes publication of the subject petition, due to the fact that this 

exemption will not set a precedent. Boeing believes good cause exists to waive the 

publication and comment requirements of 11.85, 11.87, and 11.89. 

Clarification of the limitations Imposed by Exemption 97936 will not set 

precedence. This request to revise Limitation 12 is not unprecedented. The FAA 

has granted a revision to Exemption No. 9793 to allow for installation of the crew 

slide because a corresponding level of safety is provided. Similarly, the same level 

of safety is provided by the revised Limitation, in that the design allows some 

illumination. 

Page 6 of7 
Enclosure to BDCO-11-00741 

The 747-8F petition is being provided in a timely manner; however, due to the 

scheduled delivery of the first 747-8F being mid year 2011, for the first customer 

with the escape slide chosen option, a delay in processing of the Exemption could 

delay the entry into service. 

J. Privileges of this Exemption Outside the United States 

Per 14 CFR 11.81(h), Boeing requests that the privileges of this Exemption be 

extended outside the United States. This extension of privileges is necessary for 

operations based within foreign countries having bilateral agreements with the 

United States accepting FAA 14 CFR Part 25 as their ainworthiness standards for 

transport category aircraft. The 747-8F is intended for the global market place. 

K. Conclusion 

The 747-8F maintains the level of safety previously afforded on the 747 Freighter 

series from an exit rating and evacuation systems standpoint. The 35 year service 

history of the 747F series has proven its safety. Granting relief from Limitations 12 

is justified based on the capability of the airplane to provide safe evacuation means 

including illumination. 

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